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issues for decision are: (1) Petitioner’s entitlement to
itemized deductions for job expenses, and (2) other miscellaneous
deductions.
Because petitioner is not a citizen of, and does not reside
in, the United States but earns income in the United States, she
is required to file income tax returns for the income she earns
in the United States as a nonresident alien. The income tax form
for such taxpayers is Form 1040NR, U.S. Nonresident Alien Income
Tax Return. Petitioner filed a timely return for 2001. On that
return, she reported wage and salary income of $46,534.65,
taxable State and local income tax refunds of $505, and total
income of $47,039.65. She also reported tax-exempt interest
income of $264. See supra note 2. Petitioner’s return also
included a Schedule A, Itemized Deductions, on which she claimed
deductions totaling $17,757. The Schedule A for Form 1040NR
differs from the Schedule A for Form 1040 income tax returns for
U.S. citizens. Most notably, Schedule A for Form 1040NR makes no
provision for deduction of medical expenses, although Schedule A
for Form 1040NR allows deductions for State and local taxes,
charitable contributions, job expenses, casualty and theft
losses, and most other miscellaneous deductions.
2(...continued)
tax-exempt interest. In the notice of deficiency, respondent
determined that the interest was includable in gross income. At
trial, counsel for respondent conceded that adjustment.
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